Reference Lists of Changes in Qualification Requirements for Retirement Plans FAQs


Reference Lists help you ensure that your plan document incorporates all relevant changes in plan qualification requirements and records the plan document sections amended and dates the amendments were made.

Additional resources include:

Am I required to submit reference lists with my determination letter application?

Reference lists are optional, but encouraged to facilitate IRS review of your plan document (Revenue Procedure 2023-4, Section 10.04).

Which reference lists do I complete?

For an individually designed plan submitted on Form 5300 prior to January 31, 2017, complete the five reference lists for the five years of your remedial amendment cycle (RAC) (Cycle A would complete 2015, 2014, 2013, 2012 and 2011). For an employer adopting a volume submitter plan and submitting on Form 5307, complete the six reference lists for the six years in your RAC.

Would I submit reference lists for plans involved in a merger or spinoff?

You must verify that each plan involved was qualified at the time of the merger or spinoff. Therefore, in addition to completing reference lists for the surviving plan, complete all of the reference lists up to the date of the merger for each merged plan for the current RAC.

Which reference lists would I complete if a plan has a prior favorable determination letter in the current RAC?

If a plan has a prior favorable determination letter within the current RAC because of a plan spin-off, merger, cycle-changing event, etc., only complete reference lists for the years after the year of the cumulative list on which the plan was reviewed (shown on the determination letter).

Should I complete reference lists if I’m filing a Form 5307 application for a pre-approved plan?

Yes, complete the reference lists for each of the six years in the remedial amendment cycle that applies to your Form 5307 application. See the Pre-Approved Retirement Plan Adopting Employer FAQs.

What if we didn’t amend the plan by the amendment deadline?

If you discover that amendments were not adopted by the required date, you can usually correct this plan qualification failure under the Employee Plans Compliance Resolution System (EPCRS).